People v.

Bongalon, 374 SCRA 289

Facts:
• The case involves the unlawful sale of 250.70 grams of Methamphetamine
Hydrochloride (shabu) in violation of Republic Act No. 6425, also known as The
Dangerous Drugs Act of 1972.
• The accused, Baltazar Bongalon, was accused of selling shabu on December 8,
1994, in Paranaque, Metro Manila, Philippines.
• Bongalon pleaded not guilty when arraigned, and the trial commenced.
• The prosecution's case relied on information from a confidential informant that
led to a buy-bust operation by NARCOM agents.
• The defense claimed that the arrest was unlawful, arguing that the NARCOM
agents framed Bongalon for extortion.
• Bongalon's arrest occurred when he was intercepted by armed men while driving,
taken to Camp Papa for investigation, and subsequently allowed the police to
search his house.
• After the trial, Bongalon was found guilty, sentenced to the death penalty, and
ordered to pay a fine of P1,000,000.00.
• Bongalon filed a motion for a new trial, which was denied, and he appealed the
decision.
Issue:
Whether the accused is estopped from challenging the legality of his arrest.
Ruling:
Yes, the accused is estopped from assailing the legality of his arrest. In cases involving
violations of the Dangerous Drugs Act, credibility is typically given to prosecution
witnesses who are police officers, unless there is evidence to the contrary. Additionally,
Bongalon was caught in flagrante delicto while selling shabu, and therefore, there was
no need for a warrant to effect his arrest as per Section 5(a), Rule 113 of the Revised
Rules on Criminal Procedure. The rule also states that an accused is estopped from
challenging the legality of their arrest if they fail to move to quash the information
against them before arraignment. Any objection related to the arrest or the court's
jurisdiction over the accused must be made before entering a plea, or it is considered
waived. The subsequent filing of charges and the issuance of a warrant will cure any
defect in the detention.